U.S. Securities and Exchange Commission
Washington, D.C. 20549
FORM N-17f-2
Certificate of Accounting of Securities and Similar Investments
in the Custody of Management Investment Companies
Pursuant to Rule 17f-2 [17 CFR 270.17f-2]
1. Investment Company Act File Number: Date examination completed:
811-5511 July 31, 1998
2. State Identification Number:
AL AK AZ AR CA CO
CT DE DC FL GA HI
ID IL IN IA KS KY
LA ME MD MA MI MN
MS MO MT NE NV NH
NJ NM NY NC ND OH
OK OR PA RI SC SD
TN TX UT VT VA WA
WV WI WY PUERTO RICO
Other (specify):
3. Exact name of investment company as specified in registration statement:
Variable Insurance Products Fund II: Index 500 Portfolio
4. Address of principal executive office:(number, street, city, state,
zip code)
82 Devonshire Street, Boston, MA 02109
INSTRUCTIONS
This Form must be completed by the investment companies that
have custody of securities or similar investments.
Investment Company
1. All items must be completed by the investment company.
2. Give this Form to the independent public accountant who, in
compliance with Rule 17f-2 under the Act and applicable state law,
examines securities and similar investments in the custody of the
investment company.
Accountant
3. Submit this Form to the Securities and Exchange Commission and
appropriate state securities administrators when filing the certificate
of accounting required by Rule 17f-2 under the Act and applicable
state law. File the original and one copy with the Securities and
Exchange Commission's principal office in Washington, D.C., one
copy with the regional office for the region in which the investment
company's principal business operations are conducted, and one
copy with the appropriate state administrator(s), if applicable.
THIS FORM MUST BE GIVEN TO YOUR INDEPENDENT
PUBLIC ACCOUNTANT
Report of Independent Accountants
To the Board of Trustees of:
Fidelity Concord Street Trust: Spartan U.S. Equity Index Fund
Fidelity Concord Street Trust: Spartan Total Market Index Fund
Fidelity Concord Street Trust: Spartan Extended Market Index Fund
Fidelity Commonwealth Trust: Spartan Market Index Fund
Variable Insurance Products Fund II: Index 500 Portfolio
We have examined management's assertion about Fidelity Concord Street Trust:
Spartan U.S. Equity Index Fund, Fidelity Concord Street Trust: Spartan Total
Market Index Fund,
Fidelity Concord Street Trust: Spartan Extended Market Index Fund, Fidelity
Commonwealth Trust: Spartan Market Index Fund and Variable Insurance Products
Fund II: Index 500 Portfolio (collectively the "Funds") compliance with the
requirements of subsections (b) and (c) of Rule 17f-2 under the Investment
Company Act of 1940 ("the Act") as of July 31, 1998 included in its
representation letter dated May 27, 1999. Management is responsible for the
Funds' compliance with those requirements. Our responsibility is to express
an opinion on management's assertion about the Funds' compliance based on
our examination.
Our examination was made in accordance with standards established by the
American Institute of Certified Public Accountants and, accordingly, included
examining, on a test basis, evidence about the Fund's compliance with those
requirements and performing such other procedures as we considered necessary
in the circumstances. Included among our procedures were the following
tests performed as of July 31, 1998 and with respect to agreement of security
purchases and sales, for the period from February 27, 1998 (the date of our
last examination) through July 31, 1998:
* Count and inspection of all securities located in the vault of Bankers
Trust in New York;
* Confirmation of all securities held by institutions in book entry form-The
Federal Reserve Bank of New York, The Depository Trust Company, CREST and
CHESS;
* Confirmed all securities record-kept at banks with whom the Custodian and
the Funds have contracted to provide sub-custodian services without prior
notice to management including Citicorp-Florida, Generale Bank Belgium,
Creditanstalt Bankyerein Austria, Barclays Bank London, Royal Bank of
Canada, Den Danske Bank Denmark, Merita Bank Finland, Banque Paribas France,
Dresdner Bank Germany, National Bank of Greece, Deutsche Bank India,
Standard Charter Bank Indonesia, Allied Irish Bank Ireland, Standard Charter
Bank Hong Kong, Citibank Italy, Sumitomo Bank Tokyo, Standard Charter Bank
Korea, Custodian & Nominees Malaysia, Bancomer Mexico, ABN AMRO Netherlands,
ANZ Nominees Limited, New Zealand, Euroclear Belgium, Standard Charter Bank
Pakistan, Standard Charter Bank Manila, Banco Espirito Portugal, United
Overseas Bank Singapore, Banco Santander Spain, Svenska Handelsbanken Sweden,
Swiss Bank Corp Switzerland, Barclays Bank Bostwana, Standard Charter Bank
Thailand, ABAS Securities, CEDEL, Citibank Poland, and Citibank Norway;
* Confirmation of all securities hypothecated, pledged, placed in escrow, or
out for transfer with brokers, pledgees and/or transfer agents;
* Reconciliation of all such securities to the books and records of the
Funds and the Custodian;
* Confirmation of all repurchase agreements with brokers/banks and agreement
of underlying collateral with Bankers Trust records; and
* Agreed selected securities purchased and securities sold or matured since
our last report from the books and records of the Funds to broker confirms.
We believe that our examination provides a reasonable basis for our opinion.
Our examination does not provide a legal determination on the Funds'
compliance with specified requirements.
In our opinion, management's assertion that the Funds were in compliance
with the requirements of subsections (b) and (c) of Rule 17f-2 of the
Investment Company Act of 1940 as of July 31, 1998 with respect to securities
reflected in the investment accounts of the Funds are fairly stated, in all
material respects.
This report is intended solely for the information and use of management of
the Funds and the Securities and Exchange Commission and should not be used
for any other purpose.
PricewaterhouseCoopers LLP
New York, New York
May 27, 1999
